CIBSE’s response to the Part L and Future Homes Standard is in. It was supported by a huge level of interest among members, and done in collaboration with organisations including the London Energy Transformation Initiative (LETI), RIBA, the Royal Town Planning Institute (RTPI), the Chartered Institute of Environmental Health (CIEH), and the UK Green Building Council (UK-GBC). This showed an impressive level of consensus on key aspects:
- The need for more ambition, improved fabric requirements, and attention to whole-energy consumption and the in-use stage
- Allowing leadership from local authorities to implement more onerous carbon-reduction requirements, subject to local viability testing
- The need to produce the Future Homes Standard as soon as possible, to allow early adopters, and help develop expertise and supply chains. This must include not only energy and carbon aspects, but also – hand in hand – Part F proposals to ensure good indoor air quality at improved airtightness levels
- Concerns about peak electricity demand and fuel-poverty impacts, which could result from reduced fabric performance and direct electric heating.
Next steps
The Ministry of Housing, Communities and Local Government (MHCLG) will produce a summary analysis of the responses – when is not yet known. It is currently not expected to make all submissions available, although it is possible that interested parties will submit a Freedom of Information request. After this, MHCLG will either publish the final Part L and Part F 2020 versions or – if changes that were not in the original consultation are proposed – a further consultation. The latter would probably need to happen to implement the sort of changes CIBSE has been recommending.
“A further consultation would probably need to happen to implement the sort of changes CIBSE has been recommending”
We are expecting a consultation soon on the Part L elements for non-domestic and existing buildings, and (from BEIS) on operational ratings for non-domestic buildings (for example, Display Energy Certificates, DECs). Get in touch at technical@cibse.org if you are interested in being involved – and, in particular, if you have data on in-use performance, and thoughts on changes to the National Calculation Methodology to relate more closely to in-use energy consumption.
You can also support CIBSE’s efforts by signing the Building Performance Network statement on operational performance, and committing to monitor and disclose the energy performance of the buildings you occupy (for example, through a voluntary DEC).
Beyond individual buildings
CIBSE has recently responded to the Committee on Climate Change’s call for evidence for the UK 6th carbon budget and Welsh target.
We are also preparing recommendations on planning and climate change to welcome our 11th housing minister in 10 years, including:
- Change the narrative: buildings, neighbourhoods and cities that are low carbon and incorporate green infrastructure are not a sign of nanny state, ‘banning’ or restricting people’s rights. They are places where people like to live and can deliver numerous environmental, health and wellbeing benefits.
- Review the system of incentives and requirements to truly encourage and reward schemes that offer long-term environmental and health benefits. Improve the transparency of viability assessments, starting with the very term ‘viability’, as the system actually allows much higher profits than the word implies.
- Allow and encourage climate leadership from local authorities and applicants, as highlighted in our response to the Part L and Future Homes consultation.
- Provide adequate local authority resources to implement building regulations and planning policies.
- Develop planning guidelines on topics where the planning system is central, including:
– Climate adaptation, including overheating risk
– The transition to electric vehicles and, increasingly, all-electric buildings, including consideration of the transport system and local infrastructure – for example, charging points, large-scale storage
– Low carbon and climate-adapted retrofit for heritage buildings and conservation areas. This should be done in collaboration with heritage bodies, the Institute of Historic Building Conservation (IHBC), and CIBSE, among others, to maintain the quality and integrity of our built heritage. - Review permitted development rights (PDRs): they are causing serious health and safety concerns (see CIBSE Journal, October 2019), cannot take account of public transport and local amenities, and are a missed opportunity to apply higher carbon and sustainability standards.
- Review the approach to fracking and onshore wind turbines: it is not consistent with the UK’s net-zero carbon target to allow fracking and encourage continued investment in fossil fuels, while imposing a moratorium on onshore wind turbines in England. To build acceptance from local populations and spread the benefits of onshore wind schemes, planning should require genuine community engagement and encourage community energy schemes.